California Councils of Governments: Regional Planning Bodies

Councils of Governments (COGs) are voluntary associations of local governments that serve as regional planning bodies across California. They coordinate land use, transportation, housing, and environmental programs across jurisdictions that share geographic, economic, or infrastructural interdependencies. COGs occupy a distinctive tier in California's intergovernmental structure — below state agencies and above individual cities and counties — and their decisions carry significant consequences for housing allocation, transportation funding, and air quality compliance.

Definition and scope

A Council of Governments is a joint powers authority formed under California Government Code § 6500 et seq., which authorizes two or more public agencies to jointly exercise common powers. COGs are not general-purpose governments; they hold no taxing authority and cannot enact ordinances directly enforceable against private parties. Their authority derives from delegated functions — statutory designations by the state legislature and federal government that assign specific regional planning responsibilities to these bodies.

California recognizes COGs as the designated Metropolitan Planning Organizations (MPOs) in urbanized areas with populations exceeding 50,000, a threshold established under 23 U.S.C. § 134 (federal transportation planning statutes). In this MPO capacity, COGs administer federally required Regional Transportation Plans (RTPs) and Transportation Improvement Programs (TIPs), controlling the allocation of federal surface transportation funds within their regions.

The Southern California Association of Governments (SCAG) — the largest COG in the United States by geographic coverage — serves a 6-county region encompassing Los Angeles, San Diego, Orange, Riverside, San Bernardino, and Ventura counties, covering approximately 38,000 square miles. The Association of Bay Area Governments (ABAG) serves the 9-county San Francisco Bay Area, and the Sacramento Area Council of Governments (SACOG) serves a 6-county region in the Sacramento Valley.

This page covers COGs operating within California under state and federal statutory frameworks. It does not address tribal governance structures, special districts formed under separate enabling legislation (covered at California Special Districts), or federal regional planning entities that operate independently of the COG system. Interstate compacts and multi-state planning bodies fall outside the scope of this page.

How it works

COGs operate through a governing board composed of elected officials — mayors, city councilmembers, and county supervisors — appointed by member jurisdictions. Voting weights vary by COG; some use population-weighted formulas while others assign equal votes per jurisdiction regardless of size. Policy committees and technical advisory committees staffed by local planners and engineers prepare analyses that inform board decisions.

The core statutory functions of a COG in California include:

Regional Housing Needs Allocation (RHNA): Under California Government Code § 65584, COGs receive a housing need determination from the California Department of Housing and Community Development and must allocate that need among member jurisdictions. Each city and county must then update its General Plan Housing Element to accommodate the assigned units. SCAG's 6th Cycle RHNA allocation (2021–2029) assigned approximately 1.3 million units across its region (SCAG, 6th Cycle RHNA Methodology).
Regional Transportation Planning: COGs in MPO-designated areas adopt RTPs covering a minimum 20-year horizon, consistent with requirements under 23 U.S.C. § 134 and the Fixing America's Surface Transportation (FAST) Act. These plans must conform to air quality standards established by the California Air Resources Board and the federal Clean Air Act.
Sustainable Communities Strategy (SCS): Senate Bill 375 (2008) requires MPO-designated COGs to prepare an SCS integrated into their RTP, demonstrating how regional land use and transportation patterns will achieve greenhouse gas emission reduction targets set by the California Air Resources Board.
Grant administration: COGs administer federal and state transportation funds, including Surface Transportation Block Grant Program (STBG) funds, and apply competitive project selection criteria established by their boards.

The California Department of Transportation (Caltrans) coordinates with COGs on statewide transportation planning and provides technical guidance, but does not exercise supervisory authority over COG governing boards.

Common scenarios

RHNA disputes: Member cities frequently contest their RHNA allocations, arguing that assigned unit counts exceed infrastructure capacity or conflict with local land use plans. COGs convene appeals processes under Government Code § 65584.05; however, final allocations carry legal weight — jurisdictions that fail to adopt compliant Housing Elements face penalties enforced by the California Department of Housing and Community Development, including loss of permitting authority under the builder's remedy doctrine.

Transportation project prioritization: When multiple member jurisdictions compete for a limited pool of federal transportation funds, the COG's project selection criteria determine winners. Jurisdictions that have not adopted compliant General Plans or that fail to meet programmatic requirements risk disqualification from competitive funding cycles.

SCS compliance: A COG that cannot demonstrate a viable path to its greenhouse gas reduction target must notify the California Air Resources Board. Failure to achieve conformity can trigger consequences for the region's federal transportation funding conformity determination, blocking obligation of federal funds for new transportation projects.

Inter-jurisdictional infrastructure: When a regional transit corridor, highway interchange, or water infrastructure project crosses multiple city or county boundaries, the COG typically serves as the convening body for coordination and, in some cases, as the project sponsor or fund recipient.

Decision boundaries

COGs operate within clearly defined limits that distinguish them from both state agencies and local general-purpose governments. Key boundaries:

No police power: COGs cannot zone land, issue permits, or enforce building codes. These authorities remain with cities and counties as described at California City Government Structure and California County Government Structure.
No direct taxation: COGs cannot levy taxes or assessments on private property. Revenue derives from member agency dues, federal planning grants, and state program funds.
Voluntary membership with statutory obligations: Membership is voluntary, but jurisdictions within a designated MPO boundary that withdraw lose access to federally required transportation planning processes and associated funding eligibility.
State preemption on housing: While COGs administer RHNA, the California legislature sets the overall methodology and timelines. COGs lack authority to reduce statewide housing need totals or exempt jurisdictions from Housing Element law requirements.

The distinction between a COG and a special district is structural: special districts are service-delivery entities with defined service areas and, in most cases, independent taxing authority; COGs are intergovernmental coordination bodies with planning and programming functions. The comprehensive landscape of California government — including the relationship between COGs and state-level planning agencies — is indexed at the California Government Authority.

California Councils of Governments: Regional Planning Bodies

Definition and scope

How it works

Common scenarios

Decision boundaries

References